What the FDA Has to Say About Gluten-Free Beer

As many of you know, the FDA recently released a long-overdue ruling regarding the labeling of gluten-free food. This ruling also touched on the issue of gluten-free beer labeling, though it didn’t exactly reach a clear verdict. It isn’t exactly an easy read, so for those wondering what it means, let’s break it down.

THE LABELING OF GLUTEN-FREE FOOD

“The final rule defines and sets conditions on the use of the term “gluten-free” in foods, including:

Foods that inherently do not contain gluten (e.g., raw carrots or grapefruit juice) may use the “gluten-free” claim.

Foods with any whole, gluten-containing grains (e.g., spelt wheat) as ingredients may not use the claim;

Foods with ingredients that are gluten-containing grains that are refined but still contain gluten (e.g., wheat flour) may not use the claim;Show citation box

Foods with ingredients that are gluten-containing grains that have been refined in such a way to remove the gluten may use the claim, so long as the food contains less than 20 ppm gluten/has less than 20 mg gluten per kg (e.g. wheat starch);

Foods may not use the claim if they contain 20 ppm or more gluten as a result of cross-contact with gluten containing grains.”

What does that mean? Well, it essentially says that you have to meet all those criteria to label yourself gluten-free. You first and foremost have to be below 20 ppm of gluten. You can’t use wheat, barley, or rye as direct ingredients. And you can’t use ingredients made from wheat, barley, or rye, unless that ingredient has been processed to reduce the levels of gluten to below 20 ppm.

For more information on what what this ruling means for consumers, you can check out this consumer update released by the FDA

SO WHAT DOES THIS MEAN FOR GLUTEN-FREE BEER?

Well, unfortunately, this ruling doesn’t reach a clear decision on gluten-free beer. Gluten-free beer is unique in that it is a) somewhat overseen by both the FDA and the TTB and b) difficult to test for gluten levels. The FDA essentially punted, and said they “intend to issue a proposed rule…to address the “gluten-free” labeling of beers subject to FDA’s labeling requirements.” So there’s no definitive answer yet (you can read more about this specific issue in Comment 15 towards the end of the ruling).

One issue here is that beer made from wheat, barley, and rye is not overseen by the FDA, but solely by the TTB, while beer brewed from other grains is overseen by both organizations. That’s why gluten-free beers have to show their ingredients on the labels, but regular beers don’t. The other issue, as we’ve discussed in the past, is that beer is also unique from a gluten standpoint because gluten is hydrolyzed, or broken down, during the fermentation process. While that might sound like a good thing, it actually isn’t at all. This process does not make gluten any less dangerous to celiacs, but it does make the gluten harder to test for.

What this means is that there’s currently no reliable, valid method of testing for gluten in beer. That’s why, at Aurochs, we use only naturally gluten-free grains, test our raw materials to ensure that there is not cross-contamination in the supply chain, and only brew gluten-free beer at our dedicated brewery. We feel the only way to ensure that beer is safe for celiacs is to start and end 100% gluten-free.

Unfortunately, not everyone agrees, and some companies have started producing beer made from barley, with the gluten “removed” during the process. We’ve discussed in the past why we’re very concerned with this approach, but put simply, there’s no way to be certain how much gluten is in the beer, or whether this level is actually safe. The FDA ruling appears to agree with this, stating:

“…some comments have claimed that beers made from gluten-containing grains can be processed in a way that removes gluten. We are aware of a limited number of such products in the market. As with other fermented foods, we are not aware of any scientifically valid way to evaluate these claims, and there is inadequate evidence in the record concerning the effectiveness of the commenters’ gluten removal process.”

The FDA states that they’re going to review gluten-free brewers on a case-by-case basis in the interim, but it is likely that, to avoid confusion, nothing will change until the FDA issues another ruling. This is particularly true because beer still needs to abide by the TTB’s rules, which follow the current FDA standards. And despite there being some recent confusion around what this means for “gluten-reduced” beer brewed from barley, we think the answer is pretty clear: